20091002Petition to Intervene.pdf

RECEIVED
An English Gravatt
RENEWABLE NORTHWEST PROJECT
917 SW Oak Street, Suite 303
Portland, OR 97205
Ph: [phone]
Fax: [phone]
an~mp.org
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UTILITIES COMMI;:S¡vr.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
PACIFICORP DBA ROCKY MOUNTAI
POWER FOR AN ORDER REVISING THE
WID INTEGRATION RATE FOR
WID-POWERED SMALL POWER
GENERATION QUALIFYIG FACILITIES
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PETITION TO INTERVENE
CASE NO. PAC-E-09-07
Pursuant to Idaho Public Utilities Commission Rules of Procedure 53 and 71
through 73, Renewable Northwest Project ("RNP") hereby seeks intervention in the
above-captioned matter. As discussed below, RN has direct and substatial interests in
these proceedings, and therefore should be granted intervention.
Established in 1994, RNP promotes the responsible expanion of solar, wind and
geothermal energy in the Nortwest. RNP works to establish policies that support
renewable energy development and nure the development of a market for renewable
energy. RNP's unque coalition of members includes renewable energy project
developers, public and consumer interest groups, tubine manufactuers, environmental
organizations and others. RNP's address is 917 SW Oak St, Suite 303; Portland, Oregon,
97205.
PETITION TO INTERVENE BY RNP -- 1
RNP has direct and substatial interests in this proceeding because the
Commssion's implementation of the federal Public Utilities Regulatory Policies Act
(PURPA) has significant impacts upon investment in renewable energy in Idaho. The
Commssion's decision regarding Rocky Mountain Power (RP)'s petition to increase
the avoided cost integration rate applicable to purchases by RMP from wind QFs from
$5.10 to $9.96 per MWH is likely to have significant impacts upon investment in wind
power generation in Idaho. RNP has an' interest in promoting the responsible expansion
of renewable energy in the Northwest, and decisions issued in this case may impact its
abilty to advance that interest. In addition, RNP has been previously involved with the
issue of wind integration rates before the Commission and was a par in Case No. P AC-
E-07-07, Case No. IPC-E-05-22 and others.
RNP seeks intervention in order to fully paricipate in this matter as paries and
otherwise to present such materials as may be relevant to the Commis,sion's decision(s) in
this matter. RNP intends to separately seek intervenor fuding pursuant to RP 161
though 165.
PLEASE TAKE NOTICE that RNP requests all documents in this matter be
served to the following persons:
An English Gravatt
Policy Director
Renewable Nortwest Project
917 SW Oak St, Suite 303
Portland, OR 97205
an~mp.org
Suzane Leta Liou
Senior Policy Advocate
Renewable Northwest Project
917 SW Oak St, Suite 303
Portland, OR 97205
suznne~mp.org
PETITION TO INTERVENE BY RNP-- 2
WHEREFORE, RNP respectfully requests that the foregoing petition to intervene
be granted.
Dated: September 28, 2009 Respectfully submitted,
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An English Gravatt
PETITION TO INTERVENE BY RNP -- 3
CERTIFICATE OF SERVICE
I hereby certify that on this 28th day of September 2009, tre and correct copies of
the foregoing PETITION TO INTERVENE were delivered to the following persons via
the method of service noted:
U.S. Mail and Electronic Mail:
Jean Jewell
Commssion Secretar (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Jean.jewell~puc.idaho.gov
Daniel E. Solander
Senior Counsel
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
Danel.solander~pacificorp.com
Ted Weston
Manager, Idaho Regulatory Affairs
Rocky Mountan Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
Ted. weston~pacificorp.com
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An Englis ravatt
PETITION TO INTERVENE BY RNP -- 4